Building Safety After Grenfell: Accountability Beyond the Paperwork

The Building Safety Act 2022 is a major part of the post-Grenfell reform programme, but it should not be treated as one simple UK-wide operating manual. Different provisions have different territorial application, and detailed requirements sit in regulations and related legislation.

The government’s September 2026 Grenfell progress report, updated in October, distinguishes completed work from reforms still being developed. A recommendation, consultation or proposed regulator is not automatically an operative legal requirement. Claims about future reform should be labelled accordingly. [1]

In England, the principal designer and principal contractor under building regulations have functions concerned with compliance of design and building work. Under CDM 2015, the corresponding roles concern management of construction health and safety. One organisation may hold both appointments if capable, but the functions are distinct and the appointments must be clear. [2]

For a project team, that means asking who is responsible for each decision. Who can accept a design change? Who co-ordinates its effect on the fire strategy? Who manages risks while the work is carried out? Who confirms what evidence must be retained? An organisation chart containing the right titles is only a starting point.

For England’s design-and-construction regime, the main definition combines a height of at least 18 metres ou at least seven storeys with qualifying use: at least two residential units, a hospital or a care home. Detailed definitions, measurement rules and exclusions must also be checked. The occupation regime has a different scope; the construction definition should not simply be copied into an occupied-building assessment. [3]

A building below those thresholds still has to meet relevant building and fire-safety requirements. Equally, counting visible floors from the street is not a reliable substitute for applying the legal measurement rules.

For work subject to England’s higher-risk building-control regime, controlled changes must be assessed and recorded. Some are notifiable; major changes require approval before the affected work proceeds. The current BSR guidance explains that a notifiable change must be submitted before the relevant work starts, whereas a major change must await approval. Validation of an application is not approval. [4]

A change involving openings for pipes, ducts or cables is expressly identified in the guidance as potentially notifiable. However, classification needs to consider the complete change and its consequences. A seemingly small adjustment may form part of a more significant design alteration.

In a fictional example, an electrician finds that the proposed containment route clashes with a duct. Moving it through a different wall could affect compartmentation, access, supports and other services. The correct starting point is to raise the clash and obtain an assessed, authorised solution through the project process. A product with a fire-resistance claim does not automatically make every arrangement using it suitable.

The golden thread requirements for higher-risk buildings concern maintaining and sharing reliable building information. The practical aim is that people who need to understand and manage the building can find usable, current information. A large folder of unlabelled photographs does not achieve that. [5]

A useful record for concealed work connects the location, drawing revision, product or system, relevant installation instructions, inspection outcome and any approved departure. Photographs can support that record, but their purpose matters: a photograph taken after everything is covered cannot establish every concealed detail.

Agree inspection points early. Ask what must be checked before an enclosure is closed, who can accept the work and how a rejected item will be corrected and rechecked. These are practical suggestions for making evidence useful, not a substitute for the particular project’s statutory record requirements.

England: BSR is the building-control authority for higher-risk building work within its regime. General building-regulations dutyholder duties also apply more widely. Check the project’s scope and any transitional provisions. [2–4]

Wales: a new regime began on 1 July 2026, including dutyholder and competence requirements and procedures for higher-risk building work. Local authorities carry out the Welsh higher-risk building-control function. The Welsh definition can include a building with one residential unit, and includes children’s homes, alongside the height/storey criteria and other qualifying uses and exclusions. Existing projects may fall within transitional arrangements. England’s definition and BSR application route must not be copied across. [6–7]

Scotland: use the Building (Scotland) Act 2003, the Building (Scotland) Regulations 2004 and the applicable technical handbooks and warrant procedures. The Scottish Government identifies April 2026 handbook changes; the applicable edition depends on the project’s timing and relevant transition. [8]

Northern Ireland: use the Building Regulations (Northern Ireland) 2012 as amended, relevant Technical Booklets and district-council building-control procedures. English Approved Documents are not Northern Ireland’s own statutory guidance. [9]

Before starting, establish that the information is current, the task is within your competence and the design interfaces are understood. During the work, report discrepancies and protect inspection opportunities. At handover, make the record match the completed work.

From a SKEB perspective, knowledge means understanding the applicable duties; skill means carrying out and recording the work correctly; experience means recognising where familiar methods may not fit; behaviour means escalating a problem rather than concealing it.

Accountability becomes meaningful when a person can trace a decision from the original requirement to the finished building, including who checked it and how a problem was resolved.

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1. Government — Grenfell progress report, September 2026
2. BSR — design and building-work dutyholders
3. BSR — higher-risk building guidance collection and definitions
4. BSR — making changes to a higher-risk building project
5. BSR — keeping information about a higher-risk building: the golden thread
6. Welsh Government — July 2026 transitional arrangements
7. Welsh Government — higher-risk building-control approval
8. Scottish Government — building standards and current handbooks
9. Department of Finance NI — Technical Booklets

Fact-checked against the linked sources on 8 October 2026. Educational overview: project circumstances, applicable amendments and transitional provisions must be checked before decisions are made.